New Mexico Federal District Court Decides Motion to Exclude Testimony on Hedonic Damages in Wrongful Death Case

Hedonic damages are a measure of damages recognized by New Mexico personal injury law.  They are meant to provide compensation for the pleasure of being alive.  Following a deadly collision between the driver of a motorcycle and the driver of a car, a New Mexico federal magistrate judge decided to admit qualitative expert testimony on hedonic damages and exclude expert testimony quantifying hedonic damages.

The case arose after a person riding his motorcycle collided with a person driving a car, who turned in front of the motorcycle.  The collision, which took place in Grants, New Mexico, resulted in the death of the driver of the motorcycle and the filing of a wrongful death lawsuit.  The plaintiffs were the personal representative of the wrongful death estate of the deceased motorcyclist and relatives of the deceased.  The defendants were the personal representative of the estate of the driver of the car that collided with the motorcyclist and an automobile insurance company.

The plaintiffs wished to introduce at trial testimony from an economist concerning the value of economic losses resulting from the death of the motorcyclist, including lost earning capacity and loss of household services.  The plaintiffs also sought to introduce at trial the economist’s testimony as to hedonic damages.  The defendants sought to exclude any expert testimony regarding hedonic damages.

The court applied New Mexico state law to the question of whether the law allowed for a recovery for hedonic damages, and concluded that a recovery was possible.  The court applied Federal Rule of Evidence 403 to analyze whether, and to the extent to which, expert testimony on hedonic damages was admissible at trial.  The court was presented with a difficult task insofar as the plaintiffs wanted to establish a monetary value for the damage caused by the alleged wrongful death and the defendants argued that admitting the expert testimony regarding hedonic damages would be unfairly prejudicial to them as well as misleading, speculative, and confusing to the jury.

The court struck a balance.  It decided not to allow the plaintiffs to present to the jury, via expert testimony, a dollar amount in an attempt to quantify the value of the life of the deceased motorcyclist.  The court also concluded that the risk of undue prejudice did not outweigh the probative value to the jury of qualitative expert testimony regarding the concept of hedonic damages and pointing out the areas to be considered in evaluating such damages.

Accidents can be devastating, leading to personal injuries or loss of life.  If you or your loved one was injured in an accident, there may be grounds for an award of damages.  An award of monetary damages can assist people coping with the wrongful death of a loved one. It can also help people who are injured and their families with losses, including the medical costs, lost wages, and pain and suffering caused by the accident.  To understand more about your case, call New Mexico personal injury lawyer Matthew Vance at the Law Office of Matthew Vance, P.C.  We provide a free consultation and can be reached at (505) 242-6267 or online.

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